---
title: Privacy Policy | LeanSparks
image: https://leansparks.com/hubfs/home.png
description: How LeanSparks, a fractional growth consultancy in Quebec, collects, uses, shares and protects personal information under PIPEDA and Quebec's Law 25.
---

[LeanSparks](https://leansparks.com/?hsLang=en)

- [Growth Model](https://leansparks.com/growth-strategy?hsLang=en)
- [Whitespace Sprint](https://leansparks.com/whitespace-sprint?hsLang=en)
- [Market Entry](https://leansparks.com/market-entry?hsLang=en)
- [AtmanCo](https://leansparks.com/atmanco?hsLang=en)
- [Pricing](https://leansparks.com/pricing?hsLang=en)
- [Case studies](https://leansparks.com/case-studies?hsLang=en)
- [About](https://leansparks.com/about?hsLang=en)

[Growth Snapshot](https://leansparks.com/growth-snapshot?hsLang=en) Menu

- [Growth Model](https://leansparks.com/growth-strategy?hsLang=en)
- [Whitespace Sprint](https://leansparks.com/whitespace-sprint?hsLang=en)
- [Market Entry](https://leansparks.com/market-entry?hsLang=en)
- [AtmanCo](https://leansparks.com/atmanco?hsLang=en)
- [Pricing](https://leansparks.com/pricing?hsLang=en)
- [Case studies](https://leansparks.com/case-studies?hsLang=en)
- [About](https://leansparks.com/about?hsLang=en)
- [Growth Execution Scan](https://leansparks.com/growth-execution-scan?hsLang=en)
- [Fractional CGO](https://leansparks.com/fractional-cgo?hsLang=en)
- [Network](https://leansparks.com/network?hsLang=en)
- [Contact](https://leansparks.com/contact?hsLang=en)
- [Growth Snapshot](https://leansparks.com/growth-snapshot?hsLang=en)

1. [Home](https://leansparks.com/?hsLang=en)
2. Privacy policy

Legal

# Privacy policy

Effective November 11, 2026. This policy explains how LeanSparks handles personal information when you visit leansparks.com, contact us, complete the Growth Snapshot, apply to our network or work with us as a client.

**On this page**

1. [Who we are](https://leansparks.com/privacy#who)
2. [Person in charge of personal information](https://leansparks.com/privacy#officer)
3. [What this policy covers](https://leansparks.com/privacy#scope)
4. [Personal information we collect](https://leansparks.com/privacy#collect)
5. [How we use it](https://leansparks.com/privacy#use)
6. [Consent](https://leansparks.com/privacy#consent)
7. [Who we share it with](https://leansparks.com/privacy#share)
8. [Information stored outside Quebec and Canada](https://leansparks.com/privacy#outside)
9. [Cookies and analytics](https://leansparks.com/privacy#cookies)
10. [Client engagements and confidential information](https://leansparks.com/privacy#clients)
11. [How long we keep it](https://leansparks.com/privacy#keep)
12. [How we protect it](https://leansparks.com/privacy#secure)
13. [Confidentiality incidents](https://leansparks.com/privacy#incidents)
14. [Your rights](https://leansparks.com/privacy#rights)
15. [Children](https://leansparks.com/privacy#minors)
16. [Changes to this policy](https://leansparks.com/privacy#changes)
17. [Questions and complaints](https://leansparks.com/privacy#complaints)

## 1. Who we are

LeanSparks is a fractional growth consultancy based in Quebec, Canada. We provide fractional Chief Growth Officer services, growth diagnostics, market research and validation, market entry support, workshops and, as a certified partner, AtmanCo assessment services. In this policy, "LeanSparks", "we", "us" and "our" mean LeanSparks and the business that operates it.

We follow Canada's *Personal Information Protection and Electronic Documents Act* (PIPEDA) and Quebec's *Act respecting the protection of personal information in the private sector*, as amended by Law 25. Where the two differ, we apply the stricter rule.

## 2. Person in charge of personal information

Elias Rizk, founder of LeanSparks, is the person in charge of the protection of personal information. He is accountable for how we handle personal information and for this policy.

Email: privacy@leansparks.com  
Location: Quebec, Canada

## 3. What this policy covers

This policy covers personal information about website visitors, people who contact us or complete the Growth Snapshot, prospective and current clients and their staff, network applicants and members (consultants, coaches and referral partners), and suppliers. It does not cover how AtmanCo handles assessment data on its own platform, which is governed by AtmanCo's privacy policy.

## 4. Personal information we collect

We collect only what we need for the purposes in section 5.

- **Contact and business details** you give us: name, work email, phone number, company, job title, company revenue range, and the content of your messages.
- **Growth Snapshot data**: your answers to the questionnaire, your scores on the five keys and the resulting recommendation, linked to the email you provide.
- **Network applications**: name, email, LinkedIn profile, city and country, professional profile, certifications, languages and the details of your practice.
- **Client engagement information**: names, roles and contact details of client staff we work with, meeting notes, and business information the client shares for the engagement.
- **Assessment information**: when a client uses AtmanCo through us, we may see assessment results for the people who completed them, to interpret them with the client. The assessments themselves are completed and stored on AtmanCo's platform.
- **Billing information**: billing contact, address and invoicing details. We do not store payment card numbers.
- **Website and device information**, only if you accept analytics cookies: pages visited, approximate location derived from IP address, browser and device type, and how you arrived on the site.

We do not intentionally collect sensitive information, such as health, financial account or government identification data, through the website. Please don't send it to us unless we have agreed on a specific, secure way to do so.

## 5. How we use it

- To reply to your questions and requests, and to schedule calls.
- To produce your Growth Snapshot readout and discuss it with you.
- To prepare proposals, deliver engagements, and manage the client relationship.
- To review network applications and manage network members, referrals and commissions.
- To invoice, collect payment and keep the accounting records the law requires.
- To send occasional updates about our services, only if you have agreed or the law otherwise allows it. Every message includes a way to unsubscribe, in line with Canada's Anti-Spam Legislation (CASL).
- To understand and improve how the website is used, using analytics data, only with your consent.
- To meet legal obligations and protect our rights.

We do not sell personal information. We do not use automated decision-making to make decisions about you based solely on automated processing. Growth Snapshot scores are calculated automatically from your answers, but they are recommendations for you to consider, not decisions about you.

## 6. Consent

We ask for your consent when we collect personal information, and we explain why we need it. When you submit a form, you consent to the uses described next to it and in this policy. Consent for analytics cookies is requested separately through the cookie banner and is off by default.

You can withdraw your consent at any time, subject to legal or contractual limits, by writing to privacy@leansparks.com. If withdrawing consent means we can't provide a service, we will tell you.

## 7. Who we share it with

We share personal information only as needed for the purposes above, with:

- **Service providers** who process information on our behalf, under contracts that require them to protect it and use it only for our instructions. These include HubSpot (customer relationship management and forms), Google (Google Tag Manager and Google Analytics, with consent), our website hosting provider, email and productivity tools, and our accounting provider.
- **AtmanCo**, when a client subscribes to AtmanCo through us or we coordinate assessments, so that the platform can be set up and supported.
- **Members of the LeanSparks network** who deliver part of an engagement, only for that engagement and under confidentiality obligations. We tell clients which network members are involved.
- **Professional advisors**, such as lawyers and accountants, under confidentiality obligations.
- **Authorities**, when the law requires it.
- **A buyer or successor** in a sale, merger or reorganization of the business, under an agreement that protects the information, as permitted by law.

## 8. Information stored outside Quebec and Canada

Some of our service providers, including HubSpot and Google, may store or process information in the United States or other countries. Before transferring personal information outside Quebec, we assess whether it will receive adequate protection, as Law 25 requires, and we use contracts to protect it. Information stored outside Canada may be accessible to the authorities of the country where it is held under that country's laws.

## 9. Cookies and analytics

The website works without analytics cookies. We use Google Tag Manager in Google Consent Mode, and analytics cookies from Google and HubSpot stay off unless you click **Accept analytics** in the cookie banner. If you decline, we don't set them. Your choice is saved in your browser. To change it, clear this site's data in your browser settings and choose again.

The site also stores a small value in your browser to remember your cookie choice. It contains no personal information.

## 10. Client engagements and confidential information

When we work with a client, the engagement agreement governs how we handle the client's confidential information, including any personal information about the client's employees, customers or partners that we receive. In that role we act on the client's behalf: we use the information only for the engagement, keep it confidential, protect it as described in this policy, and return or destroy it at the end of the engagement unless the agreement or the law requires otherwise.

Tools and systems we build during an engagement run on the LeanSparks stack only for the duration agreed. At the end, we transfer them to the client's systems or, if the client chooses, continue running them under a licence agreement that includes data protection terms.

## 11. How long we keep it

- Enquiries and Growth Snapshot results with no engagement: up to 24 months after our last contact, then deleted or anonymized.
- Network applications not accepted: up to 12 months.
- Client and network member records: for the relationship, then up to 7 years for legal, tax and accounting purposes.
- Analytics data: according to the retention settings of the analytics tools, which we keep to the shortest practical period.

When information is no longer needed, we destroy it or anonymize it so it can no longer identify anyone.

## 12. How we protect it

We use safeguards suited to the sensitivity of the information: access limited to people who need it, multi-factor authentication on the systems that hold it, encrypted connections (HTTPS), reputable service providers with security commitments, and confidentiality obligations for anyone who works with us. No method of transmission or storage is perfectly secure, so we cannot guarantee absolute security.

## 13. Confidentiality incidents

We keep a register of confidentiality incidents. If an incident creates a risk of serious injury, we notify the people affected and the Commission d'accès à l'information du Québec and, where PIPEDA applies, the Office of the Privacy Commissioner of Canada, as the law requires.

## 14. Your rights

Subject to the exceptions in the law, you have the right to:

- know whether we hold personal information about you, and access it;
- have inaccurate, incomplete or outdated information corrected;
- withdraw your consent;
- ask us to stop disseminating your information or to de-index it, where the law allows;
- receive computerized information you gave us in a structured, commonly used technological format, or have it sent to another organization;
- be told how we use your information and who we share it with.

To make a request, write to privacy@leansparks.com. We may need to confirm your identity. We reply within 30 days, and we don't charge for reasonable requests.

## 15. Children

Our services are for businesses. We don't knowingly collect personal information from anyone under 14. If you believe a child has sent us information, contact us and we will delete it.

## 16. Changes to this policy

We may update this policy as our services or the law change. We will post the new version on this page with its effective date and, for significant changes, tell clients and network members directly.

## 17. Questions and complaints

Contact Elias Rizk, person in charge of the protection of personal information, at privacy@leansparks.com. We will try to resolve your concern directly.

If you are not satisfied, you can contact:

- the Commission d'accès à l'information du Québec, [cai.gouv.qc.ca](https://www.cai.gouv.qc.ca), for matters under Quebec law;
- the Office of the Privacy Commissioner of Canada, [priv.gc.ca](https://www.priv.gc.ca), for matters under PIPEDA.

[LeanSparks](https://leansparks.com/?hsLang=en)

Fractional Chief Growth Officer for B2B SaaS and tech companies under $10M ARR. Quebec, Canada.

## Growth

- [Spark Growth Model](https://leansparks.com/growth-strategy?hsLang=en)
- [Growth Execution Scan](https://leansparks.com/growth-execution-scan?hsLang=en)
- [Whitespace Sprint](https://leansparks.com/whitespace-sprint?hsLang=en)
- [Market entry](https://leansparks.com/market-entry?hsLang=en)
- [Fractional CGO](https://leansparks.com/fractional-cgo?hsLang=en)
- [Pricing](https://leansparks.com/pricing?hsLang=en)

## AtmanCo

- [Overview](https://leansparks.com/atmanco?hsLang=en)
- [Implementation](https://leansparks.com/atmanco/implementation?hsLang=en)
- [Health Check](https://leansparks.com/atmanco/health-check?hsLang=en)
- [Certification](https://leansparks.com/atmanco/certification?hsLang=en)

## Solutions

- [Leadership teams](https://leansparks.com/solutions/leadership-teams?hsLang=en)
- [Team workshops](https://leansparks.com/solutions/team-workshops?hsLang=en)
- [Right people, right seats](https://leansparks.com/solutions/right-people-right-seats?hsLang=en)
- [Growth Snapshot](https://leansparks.com/growth-snapshot?hsLang=en)

## Company

- [About](https://leansparks.com/about?hsLang=en)
- [Case studies](https://leansparks.com/case-studies?hsLang=en)
- [Network](https://leansparks.com/network?hsLang=en)
- [Join the network](https://leansparks.com/network/join?hsLang=en)
- [Contact](https://leansparks.com/contact?hsLang=en)
- [LinkedIn](https://www.linkedin.com/in/eliasrizk)

© 2026 LeanSparks. All rights reserved.[Privacy policy](https://leansparks.com/privacy?hsLang=en)

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